SEC staff published a FAQ clarifying that promoting a network's current utility generally does not create a statutory expectation of profit, but that token buyback programs and certain network upgrade announcements may alter that analysis. The guidance is informal but represents current staff thinking on Howey-test application to digital assets operating in secondary markets.
For Armada's crypto-repo desk, the FAQ is relevant to collateral eligibility assessments for SOL and HYPE, both of which have active governance, upgrade cycles, and in HYPE's case, a buyback-like tokenomics mechanism. If SEC staff view those features as creating profit expectations, the securities-law characterization of those assets as repo collateral becomes more complex. Legal counsel should map each collateral asset's specific features against the FAQ factors.